July 2016

Determination Letter Changes

Amid concern from the IRS’s Advisory Committee on Tax Exempt and Government Entities that the curtailment of the determination letter program is a “mistake” and “shortsighted,” recent guidance issued by the IRS has made clear that starting in 201…

IRS Issues Proposed Regulations on Applying Section 409A to Nonqualified Plans

The Internal Revenue Service (IRS) issued proposed regulations that clarify or modify specific provisions of the final regulations under Internal Revenue Code ("Code") Section 409A. Although the proposed regulations do not become effective until finalized,…

June 2016

The Department of Labor’s Finalized Fiduciary Rule

The U. S. Department of Labor (DOL) issued its final fiduciary rule on April 6. Under this rule, the definition of "fiduciary" is expanded and ERISA’s fiduciary standards and remedies become applicable to many of the investment and asset management recom…

Is Your Summary Plan Description Complaint with the Affordable Care Act?

An employer’s number of full-time employees is critical in determining whether the employer is an applicable large employer subject to the requirements of the Affordable Care Act (“ACA”) and for determining the Employer’s Shared Responsibility paym…

New Version of the Summary of Benefits and Coverage Finalized

The Summary of Benefits and Coverage (SBC) is intended to provide a uniform format for describing health plan benefits, thereby allowing health insurance shoppers to make meaningful comparisons among available health plans, and to assist enrollees to bette…

2017 Health Savings Account Limits Released

The Internal Revenue Service has issued the 2017 guidelines for contributions and out-of-pocket expenses for Health Savings Accounts (HSAs) that are tied to high-deductible health plans. Out-of-pocket maximums are unchanged at $6,550 for individuals and $…